IRELAND | Documentation-Requirement
On 18 December 2023, the Irish Revenue issued eBrief No. 261/23 providing a new Tax and Duty Manual Part 35a-01-05 – Requests for Transfer Pricing (TP) Documentation.
BANGLADESH | Audits-Rules
Bangladesh tax authority National Board of Revenue (NBR) announced that it will conduct its first transfer pricing audit of multinational companies (MNCs) operating in the country. NBR said more companies will come under the scope of transfer pricing audit in the coming days. The tax authority also confirmed that it will deploy the arm’s length principle for the audits.
COLOMBIA | Documentation-Master file/Local file
The Colombian National Directorate of Taxes and Customs (DIAN) has published a draft resolution proposing to adjust the tax value unit the Tax Value Unit (UVT) for 2025 at COP 49,799. The UVT is utilised in various Colombian tax regulations, including determining thresholds for transfer pricing documentation requirements, such as the Local File, Master File, and CbC reporting.
EL SALVADOR | Audits
El Salvador’s Ministry of Finance has launched the “Inspectores Fiscales Sin Fronteras” programme to facilitate expert advice on tax audits. The initiative includes practical training for inspectors and auditors, aimed at enhancing their skills in identifying and addressing tax irregularities.
LUXEMBOURG | CbC reporting requirement-General rule
The Luxembourg Administration of Direct Tax has updated its Country-by-Country (CbC) reporting guidance page, including an updated CbC reporting FAQ, to reflect the latest OECD recommendations. The update addresses whether profits (losses) before income tax in Table 1 should include payments received from other Constituent Entities that are treated as dividends in the payer’s tax jurisdiction.
ESTONIA | Rates
Estonia’s Ministry of Finance announced a temporary 2% corporate tax rate for tax resident companies and permanent establishments of non-resident companies in September 2024. The draft bill is undergoing the second of three readings in the Estonian Parliament. The law will take effect on 1 January 2026 and remain in force until 31 December 2028.
INDONESIA | Incentives
Indonesia has issued Regulation No. 69 of 2024, extending the tax holiday incentives for pioneer industries as outlined in Regulation No. 130/PMK.010/2020.
ITALY | Tax Compliance
Italy’s tax authorities have sanctioned the model form for tax credit required for eligible businesses in the agriculture, forestry, fishery, and aquaculture sectors in the Single Special Economic Zone (Single SEZ); essential for obtaining the tax credit available for investments within the designated special economic zone outlined in Law Decree No. 124/2023.
MALAYSIA | Special tax rate
As Malaysia has adopted International Financial Reporting Standards, the definitions of “investment entity” and “marketable transferable tax credit” have been updated to include insurance investment entities and align with amendments to the GloBE Model Rules, net income or loss of a constituent entity in Malaysia will be based on its financial statements; if a Malaysian entity is a permanent establishment of a main entity, it must comply with reporting requirements if the main entity prepares separate financial statements for it; and the computation of the carrying value for an eligible tangible asset will include impairment loss.
POLAND | Rates
Poland has announced reduced corporate tax rate, an investment incentive deduction, a simplified VAT regime, and a flat-rate tax for small taxpayers in 2025. Small taxpayers will benefit from reduced corporate tax rates (9%). The new thresholds are based on PLN equivalents of EUR 2 million and EUR 50,000 for the investment incentive deduction.
SAUDI ARABIA | Mitigation of penalties
The Saudi Zakat, Tax, and Customs Authority (ZATCA) has issued a statement urging all taxpayers to take advantage of the “Cancellation of Fines and Exemption of Penalties Initiative,” which is set to conclude on 31 December 2024. Fines covered by the exemption include penalties for late registration, late payment, late filing of returns in all tax laws, and fines to correct VAT returns, as well as fines for violations of VAT field control related to applying the e-invoicing regulations and other VAT general regulations.
SINGAPORE | Incentives
The Singapore Parliament has passed the Economic Expansion Incentives (Relief from Income Tax) (Amendment) Bill 2024, which introduces changes to the Development and Expansion Incentive (DEI) programme. A new concessionary tax rate of 15% has been introduced for qualifying income derived on or after 1 January 2024. This rate is in addition to the existing concessionary rates of 5% and 10%. The Act is designed to encourage companies to enhance their capabilities and undertake new or expanded activities in Singapore.
PORTUGAL | Rates-National/Federal
Portugal’s Official Gazette published Law No. 45-A/2023 on 31 December 2024, which approves the Budget for 2025. Effective from 1 January 2025, the standard corporate tax rate decreased from 21% to 20%, and reduced the rate for SMEs on the first EUR 50,000 of taxable income will drop from 17% to 16%.
SPAIN | Special tax rate
Spain has published the Royal Decree-Law 10/2024 of December 23, 2024 in the Official Gazette on 24 December 2024, establishing a temporary energy levy which targets major energy companies in 2025. The levy is set at 1.2% on the net turnover from Spanish operations of 2024 with exemptions for smaller companies if their 2019 net turnover was below EUR 1 billion or if energy sector turnover from 2017-2019 was under 50% of total turnover.
AUSTRALIA | Special tax rate
The Australian Taxation Office has updated the guidance on the Global and Domestic Minimum Tax on 23 December 2024. This includes the subordinate legislation which outlines detailed computational rules under the Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024. The GloBE Rules provide for a coordinated system of taxation intended to ensure multinational enterprise groups (MNE groups) are subject to a global minimum tax rate of 15% in each of the jurisdictions where they operate. They are a key part of the Organisation for Economic Co-operation and Development (OECD)/G20 Two-Pillar Solution, to address the tax challenges arising from the digitalisation of the economy.
BRAZIL | Special tax rate
The President of Brazil, Luiz Inácio Lula da Silva, enacted Law No. 15,079/24, implementing the OECD’s Pillar Two global minimum tax and introduces the global anti-base erosion (GloBE) regulations on 30 December 2024. The Law establishes a minimum effective tax rate of 15% through an additional charge on the social contribution on net profits. The newly instituted minimum tax applies to multinational groups with consolidated annual revenues of at least EUR 750 million for at least two of the four fiscal years.
KOREA (THE REPUBLIC OF) | Special tax rate
South Korea has published Law No. 20612 in the Official Gazette on 31 December 2024, amending the International Tax Adjustment Act, which includes several adjustments to the Global Minimum Tax provisions. The law introduces measures aligned with the OECD’s Pillar Two GloBE Model Rules, including special treatment for losses allowing 15% of GloBE losses as deferred tax assets; Transitional UTPR Safe Harbour now sets the UTPR Top-up Tax to zero for Ultimate Parent Entity (UPE) jurisdictions with a corporate tax rate of at least 20%; and the correction claim system for arm’s length price adjustments is improved to enhance the management of overseas tax sources; etc.
KUWAIT | Special tax rate
Kuwait has adopted OECD’s Pillar Two global minimum tax with the publication of Decree No. 157/2024 in the Official Gazette on 30 December 2024. The decree imposes a 15% minimum tax rate on multinational enterprise (MNE) groups that generate over EUR 750 million in annual consolidated revenue for at least two of the past four years.
NETHERLANDS | Special tax rate
The Netherlands has published the Minimum Tax Implementation Decree 2024 in the Official Gazette No. 2024/442, on 23 December 2024, which contains rules for implementing the Minimum Tax Act 2024. It outlines guidelines for implementing OECD Pillar Two, including the 15% minimum tax rate for multinational enterprises (MNEs).
PAKISTAN | Special tax rate
President Asif Ali Zardari has enacted the Income Tax (Amendment) Ordinance 2024 on 28 December, which establishes new corporate tax rates for banks. Under the ordinance, banks will face a 44% tax rate for the 2025 tax year (from 39%), gradually decreasing to 43% in 2026 and 42% in 2027 and beyond. For small enterprises, the tax rate is maintained at 20%, whereas for all other businesses, it is set at 29%.
AUSTRALIA | CbC reporting requirement-General rule
Australia has published the Taxation Administration (Country by Country Reporting Jurisdictions) Determination 2024, listing jurisdictions for public Country-by-Country (CbC) reporting on 12 December 2024. Notably, Liechtenstein has been excluded from the final determination.
AUSTRALIA | CbC reporting requirement-General rule
Australia’s laws on Public Country-by-Country (PCbC) reporting requirements received Royal Assent on 10 December 2024. Previously, on 29 November 2024, the parliament enacted legislation mandating all multinational groups to publicly disclose country-by-country (PCbCR) tax information starting from 1 July 2024.
COLOMBIA | Documentation-Requirement
On 4 December 2024, the Colombian National Tax and Customs Directorate (DIAN) issued Resolution No. 000193, establishing the tax value unit (UVT) at COP 49,799. The UVT is used across various Colombian tax regulations, including calculating tax penalties, defining individual income tax brackets, and setting thresholds for transfer pricing documentation requirements, such as the Local File, Master File, and CbC reporting.
GERMANY | Scope of transfer pricing rules
On 12 December 2024, the German Ministry of Finance issued BMF Letter No. 2024/1078709, updating the 2024 transfer pricing guidelines. The revised guidelines provide clarity on key aspects of transfer pricing, including income correction, competition considerations, and the selection of appropriate pricing methods such as the resale price and cost-plus methods.
ITALY | Special rules for hybrid instruments or entities
Italy’s Ministry of Economy and Finance has issued the Decree of 6 December 2024, detailing penalty relief provisions for violations of the country’s hybrid mismatch rules. These penalty relief measures are derived from Legislative Decree No. 209, dated 27 December 2023. The hybrid mismatch rules, established under Decree No. 142 of 2018, were introduced to align with the EU Anti-Tax Avoidance Directive (ATAD).
RUSSIA | Information exchange-Multilateral
The Russian Federal Tax Service (FTS) has updated its list of jurisdictions for automatic exchange of country-by-country (CbC) reports, effective 31 December 2024. The revised list comprises 45 states and 10 territories, compared to the previous list of 67 states and 8 territories.
SWITZERLAND | Information exchange-Multilateral
The Swiss Official Gazette published an updated MCAA participant list on 3 December 2024 (Decision No. RO 2024 738), adding Armenia, Georgia, and Montenegro. Montenegro joins on 1 January 2024, Georgia on 1 January 2025, and Armenia on 1 January 2026.
TAIWAN | Documentation-Requirement
Taiwan’s Ministry of Finance has issued a reminder to taxpayers about the approaching deadline for submitting the Master File and CbC Report for the fiscal year 2023. Profit-seeking enterprises that meet the conditions and use the calendar year as their fiscal year must submit these reports by 31 December 2024. See the story in RegBriefing.
COSTA RICA | Main corporate tax rates
Costa Rica’s Ministry of Finance has published Executive Decree No. 44772-H in the Official Gazette on 3 December 2024, establishing the corporate tax brackets and rates for the 2025 fiscal year. A corporate income tax rate of 30% applies to companies with gross income over CRC 119,629,000, while smaller companies with lower gross income are taxed at 5% with income up to CRC 5,642,000, 10% over CRC 5,642,000 and up to 8,465,000, 15% over CRC 8,465,000 and up to 11,286,000, 20% over CRC 11,286,000 and up to 119,629,000: 20%. The Decree went into effect on 1 January 2025.
FRANCE | Special tax rate
France has issued Decree No. 2024-1126 on 4 December 2024 in the Official Gazette, which sets out the regulations for implementing the Pillar Two global minimum tax (GloBE) rules as part of the Finance Law for 2024 (Law No. 2023-1322 of 29 December 2023). The Decree ensures a 15% minimum tax for MNE groups, a Qualified Domestic Minimum Top-Up Tax (QDMTT) for in-scope groups, applicable from 31 December 2023, with UTPR effective from 31 December 2024.
HONG KONG | Special tax rate
Hong Kong announced that the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Bill 2024 was published in the Gazette on 27 December 2024. The Bill implements the international tax reform framework, Base Erosion and Profit Shifting (BEPS) 2.0, promulgated by OECD in October 2021, and the global minimum tax and the Hong Kong minimum top-up tax (HKMTT) from 2025.
KOREA (THE REPUBLIC OF) | Special tax rate
The South Korean National Assembly approved the 2024 Tax Law Amendment Bill on 10 December 2024. It introduces changes to the Global Anti-Base Erosion (GloBE) rules. One of the key updates is the introduction of a transitional UTPR safe harbour for jurisdictions with a nominal corporate tax rate of at least 20%. Multinational enterprises (MNEs) will have the option to choose between the UTPR and transitional CbCR safe harbours for applicable jurisdictions. Permanent safe harbour is also being introduced, setting the criteria for simplified calculations.
LUXEMBOURG | Main corporate tax rates
Luxembourg has enacted the bill on the Corporate Income Tax (CIT) rate reduction on 20 December 2024. The legislation reduced the CIT rate by 1%, lowering the global tax rate for companies operating in Luxembourg City with taxable income above EUR 200,000. For the 2025 tax year, the rate was decreased from 24.94% to 23.87%. The law was published in Official Gazette No. A 589 on 24 December 2024.
SWEDEN | Special tax rate
The Swedish Official Gazette published Law No. SFS 2024:1248 on 11 December 2024, amending the Additional Tax Act to implement the Pillar Two global minimum tax into domestic law. The new regulations are set to come into force on 1 January 2025. The new legislation establishes provisions to define taxable persons, transactions, and economic activities subject to the rules. It specifies tax liability and outlines exemptions for certain entities, such as public bodies and non-profit organisations, as well as conditions for exempt entities and special units. The legislation also provides methods for calculating adjusted taxable results, tax costs, and additional tax amounts, incorporating deferred tax adjustments and recognising tax credits where applicable. It introduces specific regulations for certain entities, including investment units and insurance investment units, ensuring tailored application of the tax rules.
UNITED KINGDOM | Special tax rate
The UK tax authority, HMRC, has published Explanatory Notes outlining the government amendments, which focus on matters related to Pillar Two, to the Finance Bill 2024-25 on 19 December 2024. The Explanatory Notes outline the amendments introduced in the Finance (No. 2) Act 2023, which establish the multinational top-up tax (MTT) and the domestic top-up tax (DTT).
UNITED STATES MINOR OUTLYING ISLANDS (THE) | Tax Compliance
The US Internal Revenue (IRS) has announced the expansion of its Business Tax Account (BTA), a convenient online self-service tool, to include C corporations, on 12 December 2024, which allows designated officials (DOs), who are authorised to bind the corporation, to utilise the platform legally. It also includes new features such as tax returns, tax accounts, and entity transcripts for the current tax year and some previous tax years. The new features allow DOs to view and pay their corporation’s tax balances and make federal tax deposits (FTDs).
